India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Embedded profit, rather than the entire value of alleged bogus diamond purchases, is taxable where books of account remain accepted, stock and quantitative records show no adverse discrepancy, and corresponding sales are not disproved. Where accommodation bills cover goods actually sourced from other parties, the addition should be confined to the profit arising from that arrangement. A 3% profit estimate applies where no distinguishing material warrants a different estimate, including for later assessment years involving identical transaction facts.
Embedded profit, rather than the entire value of alleged bogus diamond purchases, is taxable where books of account remain accepted, stock and quantitative records show no adverse discrepancy, and corresponding sales are not disproved. Where accommodation bills cover goods actually sourced from other parties, the addition should be confined to the profit arising from that arrangement. A 3% profit estimate applies where no distinguishing material warrants a different estimate, including for later assessment years involving identical transaction facts.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4868 
